Privacy Policy (GDPR)

Name and Address of the Controller

The controller within the meaning of the Datenschutz-Grundverordnung (DSGVO – General Data Protection Regulation / GDPR) and other national data protection laws of the member states, as well as other data protection regulations, is:

ASP Andrea Sprenger Projektmanagement & EDV Consulting
c./o. D4O - Die 4te Offenbarung
Ringofenstr. 33
44287 Dortmund
Deutschland
Tel.: +49 231 453198
E-Mail: mail@as-projekt.de
Website: www.d4o.de

Name and Address of the Data Protection Officer

The Data Protection Officer of the Controller is:

Christian Sprenger
Ringofenstr. 33
44287 Dortmund
Deutschland
Tel.: +49 231 453198
E-Mail: csp@as-projekt.de
Website: www.d4o.de

General Information on Data Processing

Scope of Processing of Personal Data

We process personal data of our Users as a matter of principle only insofar as this is necessary for the provision of a functional website as well as our content and services. The processing of personal data of our Users is regularly carried out only with the User’s consent. An exception applies in cases where it is not possible to obtain prior consent for factual reasons and the processing of data is permitted by law. The following paragraphs also apply to the use of our website via a browser, as well as the use of the game service via the client software.

Insofar as we obtain consent from the data subject for the processing of personal data, Art. 6 para. 1 lit. a of the EU Datenschutz-Grundverordnung (DSGVO / GDPR) serves as the legal basis.

For the processing of personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b DSGVO (GDPR) serves as the legal basis. This also applies to processing operations that are necessary for the implementation of pre-contractual measures.

Insofar as the processing of personal data is necessary for the fulfillment of a legal obligation to which our company is subject, Art. 6 para. 1 lit. c DSGVO (GDPR) serves as the legal basis.

In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO (GDPR) serves as the legal basis.

If the processing is necessary to safeguard a legitimate interest of our company or a third party, and if the interests, fundamental rights, and fundamental freedoms of the data subject do not override the former interest, Art. 6 para. 1 lit. f DSGVO (GDPR) serves as the legal basis for the processing.

Data Deletion and Storage Duration

The personal data of the data subject shall be deleted or blocked as soon as the purpose of storage ceases to apply. Storage may furthermore take place if this has been provided for by the European or national legislator in EU regulations, laws, or other provisions to which the Controller is subject. Data shall also be blocked or deleted when a storage period prescribed by the aforementioned standards expires, unless there is a necessity for the further storage of the data for the conclusion or performance of a contract.

Provision of the Website and Creation of Log Files

Description and Scope of Data Processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing device.

The following data is collected in this process:

  • Information about the browser type and version used
  • The User’s operating system
  • The User’s internet service provider
  • The User’s IP address
  • Date and time of access
  • Websites from which the User’s system reached our website
  • Websites accessed by the User’s system through our website

The data is also stored in the log files of our system. This data is not stored together with other personal data of the User.

The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f DSGVO (GDPR).

Purpose of Data Processing

The temporary storage of the IP address by the system is necessary to enable delivery of the website and the offered service to the User’s computer. For this purpose, the User’s IP address must remain stored for the duration of the session.

Storage in log files takes place to ensure the functionality of the website and the service offering. In addition, the data serves to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes also constitute our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f DSGVO (GDPR).

Duration of Storage

The data is deleted as soon as it is no longer necessary for the purpose for which it was collected. In the case of data collected for the provision of the website, this is the case when the respective session has ended.

In the case of storage of data in log files, this is the case after no more than seven days. Storage beyond this period is possible. In this case, the Users’ IP addresses are deleted or anonymized so that an association with the accessing client is no longer possible. In the case of game data stored by the server, such data is deleted after 8 weeks.

Right to Object and Removal

The collection of data for the provision of the website, the service offering, and the storage of data in log files is essential for the operation of the website and the game servers. Consequently, the User has no right to object.

Use of Cookies

Description and Scope of Data Processing

Our website uses cookies. Cookies are text files that are stored in or by the internet browser on the User’s computer system. When a User accesses a website, a cookie may be stored on the User’s operating system. This cookie contains a characteristic string that enables unique identification of the browser when the website is accessed again.

We use cookies to make our website more user-friendly. Some elements of our website require that the accessing browser can be identified even after a page change.

The following data is stored and transmitted in the cookies:

  • Language settings
  • Login information

We also use cookies on our website that enable analysis of the User’s browsing behavior.

The following data may be transmitted in this manner:

  • Search terms entered
  • Frequency of page views
  • Use of website functions

The data collected from Users in this manner is pseudonymized through technical measures. Therefore, an association of the data with the accessing User is no longer possible. The data is not stored together with other personal data of the Users.

When accessing our website, Users are informed by an info banner about the use of cookies for analytical purposes and are referred to this privacy policy. A notice is also provided in this context on how the storage of cookies can be prevented in the browser settings.

When accessing our website, the User is informed about the use of cookies for analytical purposes and their consent to the processing of personal data used in this context is obtained. A reference to this privacy policy is also provided in this context.

The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f DSGVO (GDPR).

The legal basis for the processing of personal data using cookies for analytical purposes, where the User has given consent, is Art. 6 para. 1 lit. a DSGVO (GDPR).

Purpose of Data Processing

The purpose of using technically necessary cookies is to simplify the use of websites for Users. Some functions of our website cannot be offered without the use of cookies. For these functions, it is necessary that the browser is recognized even after a page change.

We require cookies for the following applications:

  • Shopping cart
  • Adoption of language settings
  • Remembering search terms

The user data collected through technically necessary cookies is not used to create user profiles.

The use of analytical cookies serves the purpose of improving the quality of our website and its content. Through the analytical cookies, we learn how the website is used and can thus continuously optimize our offering.

These purposes also constitute our legitimate interest in the processing of personal data pursuant to Art. 6 para. 1 lit. f DSGVO (GDPR).

Duration of Storage, Right to Object and Removal

Cookies are stored on the User’s computer and transmitted to our site by the User. Therefore, as a User, you also have full control over the use of cookies. By changing the settings in your internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies for our website are disabled, it may no longer be possible to use all functions of the website to their full extent.

Newsletter

Description and Scope of Data Processing

No newsletters are currently offered.

Registration

Description and Scope of Data Processing

On our website, or in the Accounting system, we offer Users the option to register by providing personal data. The data is entered in an input form and transmitted to us and stored. The data is not shared with third parties. The following data is collected during the registration process:

  • Name, address, date of birth

In the event that the User selects “direct debit” as a payment method, the bank details will also be stored.

At the time of registration, the following data is also stored:

  • The User’s IP address
  • Date and time of registration

Consent of the User for the processing of this data is obtained during the registration process.

Our free online offering can generally be used without disclosing one’s identity. If one decides to register, i.e., signs up as a member (registered user), personal information can be stored in the individual user profile. Whether or not this data is entered is entirely at the User’s discretion.

The legal basis for the processing of data, where the User has given consent, is Art. 6 para. 1 lit. a DSGVO (GDPR).

If the registration serves the performance of a contract to which the User is a party or the implementation of pre-contractual measures, the additional legal basis for the processing of data is Art. 6 para. 1 lit. b DSGVO (GDPR).

Purpose of Data Processing

Registration of the User is necessary for the performance of a contract with the User or for the implementation of pre-contractual measures.

This relates to the provision of game servers, game clients, and the associated services. The data is used to ensure a clear assignment of the game account and the services used to the respective User. This is essential for the operation of the game.

Duration of Storage

The data is deleted as soon as it is no longer necessary for the purpose for which it was collected.

For data collected during the registration process for the performance of a contract or for the implementation of pre-contractual measures, this is the case when the data is no longer necessary for the performance of the contract. Even after the conclusion of the contract, it may be necessary to store personal data of the contractual partner in order to fulfill contractual or legal obligations. This includes data for tax purposes. In this regard, we are obligated to store this data for 10 years.

Right to Object and Removal

As a User, you have the right to cancel your registration at any time. You may have the data stored about you amended at any time.

To do so, the User may adjust their data in the Accounting system or request deletion by e-mail to the Data Protection Officer.

If the data is necessary for the performance of a contract or for the implementation of pre-contractual measures, early deletion of the data is only possible insofar as contractual or legal obligations do not preclude deletion.

Contact Form and E-Mail Contact

Description and Scope of Data Processing

A ticket system is available on our website, which can be used for electronic contact. If a User makes use of this option, the data entered in the input form is transmitted to us and stored. This data includes:

  • Account or character name
  • Subject and inquiry

At the time the message is sent, the following data is also stored:

  • The User’s IP address
  • Date and time of registration

Consent for the processing of data is obtained during the sending process and reference is made to this privacy policy.

Alternatively, contact can be made via the e-mail address provided. In this case, the personal data transmitted with the e-mail will be stored.

No disclosure of data to third parties takes place in this context. The data is used exclusively for processing the conversation.

The legal basis for the processing of data, where the User has given consent, is Art. 6 para. 1 lit. a DSGVO (GDPR).

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f DSGVO (GDPR). If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b DSGVO (GDPR).

Purpose of Data Processing

The processing of personal data from the input form serves solely for the purpose of handling the contact request. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in the processing of the data.

The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

Duration of Storage

The data is deleted as soon as it is no longer necessary for the purpose for which it was collected. For personal data from the contact form input and those sent by e-mail, this is the case when the respective conversation with the User has ended. The conversation is considered ended when it can be inferred from the circumstances that the matter in question has been conclusively resolved.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

Right to Object and Removal

The User has the right to revoke their consent to the processing of personal data at any time. If the User contacts us by e-mail, they may object to the storage of their personal data at any time. In such a case, the conversation cannot be continued.

To do so, the User must inform us of the revocation of the processing of their personal data by postal mail.

All personal data stored in the course of the contact will be deleted in this case.

Web Analytics

Scope of Processing of Personal Data

We use the open-source software tool Matomo (formerly PIWIK) on our website to analyze the browsing behavior of our Users. The software sets a cookie on the User’s computer (for cookies, see above). When individual pages of our website are accessed, the following data is stored:

  • Two bytes of the IP address of the User’s accessing system
  • The accessed web page
  • The website from which the User reached the accessed web page (referrer)
  • The sub-pages accessed from the accessed web page
  • The time spent on the web page
  • The frequency of access to the web page

The software runs exclusively on the servers of our website. Personal data of the Users is stored only there. The data is not shared with third parties.

The software is configured so that IP addresses are not stored in full; instead, 2 bytes of the IP address are masked (e.g., 192.168.xxx.xxx). In this way, an association of the truncated IP address with the accessing computer is no longer possible.

The legal basis for the processing of the Users’ personal data is Art. 6 para. 1 lit. f DSGVO (GDPR).

Purpose of Data Processing

The processing of the Users’ personal data enables us to analyze the browsing behavior of our Users. By evaluating the data obtained, we are able to compile information about the use of the individual components of our website. This helps us to continuously improve our website and its user-friendliness. These purposes also constitute our legitimate interest in the processing of data pursuant to Art. 6 para. 1 lit. f DSGVO (GDPR). The anonymization of the IP address adequately accounts for the Users’ interest in the protection of their personal data.

Duration of Storage

The data is deleted as soon as it is no longer needed for our recording purposes.

In our case, this is after 6 months.

Right to Object and Removal

Cookies are stored on the User’s computer and transmitted to our site by the User. Therefore, as a User, you also have full control over the use of cookies. By changing the settings in your internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies for our website are disabled, it may no longer be possible to use all functions of the website to their full extent.

Further information on the privacy settings of Matomo software can be found at the following link: https://matomo.org/docs/privacy/.

Rights of the Data Subject

If your personal data is processed, you are a data subject within the meaning of the DSGVO (GDPR) and you have the following rights vis-a-vis the Controller:

Right of Access

You may request confirmation from the Controller as to whether personal data concerning you is being processed by us.

If such processing takes place, you may request the following information from the Controller:

  1. the purposes for which the personal data is being processed;

  2. the categories of personal data being processed;

  3. the recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed;

  4. the planned duration of storage of the personal data concerning you, or, if specific information in this regard is not possible, criteria for determining the storage duration;

  5. the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the Controller, or a right to object to such processing;

  6. the existence of a right to lodge a complaint with a supervisory authority;

  7. all available information about the origin of the data, if the personal data is not collected from the data subject;

  8. the existence of automated decision-making, including profiling, pursuant to Art. 22 para. 1 and 4 DSGVO (GDPR) and – at least in those cases – meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to request information about whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 DSGVO (GDPR) in connection with the transfer.

Right to Rectification

You have a right to rectification and/or completion vis-a-vis the Controller if the processed personal data concerning you is inaccurate or incomplete. The Controller shall carry out the rectification without undue delay.

Right to Restriction of Processing

You may request the restriction of the processing of personal data concerning you under the following conditions:

  1. if you contest the accuracy of the personal data concerning you for a period that enables the Controller to verify the accuracy of the personal data;

  2. the processing is unlawful and you refuse the erasure of the personal data and instead request the restriction of the use of the personal data;

  3. the Controller no longer needs the personal data for the purposes of processing, but you require it for the establishment, exercise, or defense of legal claims; or

  4. if you have objected to the processing pursuant to Art. 21 para. 1 DSGVO (GDPR) and it has not yet been determined whether the legitimate grounds of the Controller override your grounds.

Where the processing of personal data concerning you has been restricted, such data may – apart from being stored – only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.

If the restriction of processing has been restricted under the above conditions, you will be informed by the Controller before the restriction is lifted.

Right to Erasure

Obligation to Erase

You may request the Controller to erase the personal data concerning you without undue delay, and the Controller shall be obligated to erase such data without undue delay, if one of the following grounds applies:

  1. The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.

  2. You withdraw the consent on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a DSGVO (GDPR), and there is no other legal basis for the processing.

  3. You object to the processing pursuant to Art. 21 para. 1 DSGVO (GDPR) and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para. 2 DSGVO (GDPR).

  4. The personal data concerning you has been unlawfully processed.

  5. The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union law or the law of the Member States to which the Controller is subject.

  6. The personal data concerning you was collected in relation to information society services offered pursuant to Art. 8 para. 1 DSGVO (GDPR).

Information to Third Parties

Where the Controller has made the personal data concerning you public and is obligated to erase it pursuant to Art. 17 para. 1 DSGVO (GDPR), the Controller shall take reasonable measures, including technical measures, taking into account available technology and the cost of implementation, to inform controllers who process the personal data that you, as the data subject, have requested the erasure of all links to such personal data or of copies or replications of such personal data.

Exceptions

The right to erasure does not apply insofar as the processing is necessary:

  1. for the exercise of the right to freedom of expression and information;

  2. for compliance with a legal obligation which requires processing under Union or Member State law to which the Controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;

  3. for reasons of public interest in the area of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 DSGVO (GDPR);

  4. for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes pursuant to Art. 89 para. 1 DSGVO (GDPR), insofar as the right referred to in section (a) is likely to render impossible or seriously impair the achievement of the objectives of such processing; or

  5. for the establishment, exercise, or defense of legal claims.

Right to Notification

If you have exercised the right to rectification, erasure, or restriction of processing vis-a-vis the Controller, the Controller is obligated to notify all recipients to whom the personal data concerning you has been disclosed of such rectification or erasure of data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You have the right vis-a-vis the Controller to be informed about these recipients.

Right to Data Portability

You have the right to receive the personal data concerning you, which you have provided to the Controller, in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the Controller to whom the personal data was provided, provided that:

  1. the processing is based on consent pursuant to Art. 6 para. 1 lit. a DSGVO (GDPR) or Art. 9 para. 2 lit. a DSGVO (GDPR) or on a contract pursuant to Art. 6 para. 1 lit. b DSGVO (GDPR); and

  2. the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, insofar as this is technically feasible. The freedoms and rights of other persons must not be impaired thereby.

The right to data portability does not apply to the processing of personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.

Right to Object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 lit. e or f DSGVO (GDPR); this also applies to profiling based on these provisions.

The Controller shall no longer process the personal data concerning you, unless the Controller can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing serves the establishment, exercise, or defense of legal claims.

Where personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you shall no longer be processed for such purposes.

You have the option, in connection with the use of information society services – notwithstanding Directive 2002/58/EC – of exercising your right to object by means of automated procedures using technical specifications.

You have the right to withdraw your consent under data protection law at any time. The withdrawal of consent shall not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

Automated Individual Decision-Making, Including Profiling

You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision:

  1. is necessary for the conclusion or performance of a contract between you and the Controller,

  2. is authorized by Union or Member State law to which the Controller is subject, and such law contains appropriate measures to safeguard your rights and freedoms and your legitimate interests, or

  3. is made with your explicit consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 DSGVO (GDPR), unless Art. 9 para. 2 lit. a or g DSGVO (GDPR) applies and appropriate measures have been taken to safeguard your rights and freedoms and your legitimate interests.

With regard to the cases referred to in (1) and (3), the Controller shall take appropriate measures to safeguard your rights and freedoms and your legitimate interests, which include at least the right to obtain human intervention on the part of the Controller, to express one’s point of view, and to contest the decision.

Right to Lodge a Complaint with a Supervisory Authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement, if you believe that the processing of personal data concerning you infringes the DSGVO (GDPR).

The supervisory authority with which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 DSGVO (GDPR).

Supplementary Notes

Notice for Parents

We are aware that we bear a special responsibility for personal data provided to us by children. We recommend that parents instruct their children never to disclose their real names, addresses, or telephone numbers online without the permission of their guardians. Children under the age of 12 should not submit any information to us at all. We hereby declare that we will under no circumstances knowingly evaluate data submitted to us by children aged 12 or younger.

Children between the ages of 13 and 17 should ask their parents to read these privacy principles and to contact us if they wish to make use of our options for restricting services or raise any concerns.

Minors under the age of 18 should not register online for paid services without the prior permission of their parents or guardians. We ask parents and guardians to be particularly vigilant in ensuring that their children do not violate any laws while using our websites or online services.

By using the services offered on our websites, you agree to our privacy principles. If you do not agree with these principles, you should not use the services on these websites.